The six-year New York campaign to ban fracking had been backed by hundreds of artists, actors, musicians and celebrities, such as Lady Gaga, Yoko Ono, Mark Ruffalo and the late Pete Seeger. There had also been massive opposition from 250 grassroots groups fearful of the effects of fracking on everything from tourism to property prices. But while the celebs and groups may have shifted public opinion with film, social media, music and meetings, it was the new science that spoke most loudly to governor Andrew Cuomo and his advisers.

“I will be bound by what the experts say,” said Cuomo, likening fracking to passive smoking, which wasn’t fully understood as a health risk for many years.

Howard Zucker, New York’s acting health commissioner, said he had identified “significant” public health risks. “The potential risks are too great,” he said. “The cumulative concerns of what I’ve read gives me reason to pause ... I asked myself, ‘would I let my family live in a community with fracking?’ The answer is no. I therefore cannot recommend anyone else’s family to live in such a community either.”

I have read in full the 184-page New York health department report and it is an overwhelming cry by scientists for government to keep a moratorium until more is known. The sheer number of peer-reviewed scientific papers cited and reviewed by the state is impressive. Over 100 pages of references and abstracts of studies, mostly published in the last year or two, are included. New reports have found air pollution, elevated climate emissions, widespread drinking water contamination, excess methane in water, numerous surface spills and noise exposure.

Fracking involves thousands of gallons of water being mixed with cocktails of chemicals and sand and pumped deep into the earth to break up gas-rich shale rock formations. The New York review of the science revealed people living near active sites have reporting nausea, abdominal pain, nosebleeds, and headaches, as well as skin rashes and excess cancers and psychological stress. A Colorado study, which examined 124,842 births between 1996 and 2009, found that those who lived closest to natural gas development sites had a 30% increase in congenital heart conditions.

The “List of the Harmed”, maintained by the Pennsylvania Alliance for Clean Water and Air, documents more than 6,000 reports from around the country.

Faced with such mounting evidence Zucker recommended a ban:

The overall weight of the evidence from the cumulative body of information demonstrates that there are significant uncertainties about the kinds of adverse health outcomes that may be associated with high volume hydraulic fracturing (HVHF), the likelihood of the occurrence of adverse health outcomes, and the effectiveness of some of the mitigation measures in reducing or preventing environmental impacts which could adversely affect public health. Until the science provides sufficient information to determine the level of risk to public health from high volume hydraulic fracking... the department of health recommends that HVHF should not proceed.

Now compare the growing health concerns of US scientists with the assurances given by the UK government that fracking is safe and that any problems can be legislated for. For some context, I spoke to Sandra Steingraber, Ithaca university biologist and author who co-founded New Yorkers Against Fracking:

We began in [scientific] ignorance in 2008 when there were just six studies into the health effects of fracking. Now there are 412. Over 70% of all the available peer-reviewed papers have been published in the past two years, with a current average of one paper published each day; 87% of original research studies indicate potential risks or adverse health outcomes; 95% indicate elevated concentrations of air pollutants, and 72% of water studies indicate potential or actual incidence of contamination. It became very clear to health professionals and scientists that scientific studies of the environmental and health dangers ... had begun to emerge in a substantial way. Their findings were alarming, showing health and environmental impacts and leaving unanswered questions about the extent of even further risks.

Steingraber continued:

As a public health biologist, I [now] see fracking as the most dangerous industrial practice that I have ever seen. The new data clearly show that fracking... cannot be made safe through any regulatory framework. In densely-populated regions, like the UK and New York, public health consequences are unavoidable. Prevention of public health impacts are not possible as long as drilling and fracking operations pour carcinogenic benzene into the air. Old wells leak. New wells leak methane and benzene. And these leaks cannot be fixed fast enough to compensate for the increasing numbers of wells that must continuously be brought on line to take the place of depleted wells – which themselves go on leaking into retirement and beyond.

Protesters demand a statewide ban on hydraulic fracturing in New York City. The protest was held outside a Democratic party event with New York Governor Andrew Cuomo attending. Photograph: Andrew Burton/Getty Images

But this new health science appears to have not been seen by the British authorities, or if it has, has been tacitly ignored. Here, where local data is admittedly limited to to one operator, regulation relies heavily on the industry regulating itself. The decision on whether to frack or not is taken by several government departments, which are under great political pressure to speed exploitation.

Regulatory authority in the US falls to states but in the UK the Health and safety executive (HSE) oversees working practices, and an industry body, the UK Onshore Operators Group (UKOOG), issues guidelines for operators on well integrity. Meanwhile, the Department for Environment, Food and Rural Affairs (Defra) and the Environment Agency (EA) are responsible for the regulatory regime and the physical environmental impact.

Where New York included 100 pages of scientific studies, the British authors searched the scientific literature on the health impacts up to 2014 and devoted just six pages to air pollution, five to water risks, and seven to naturally occurring radioactivity. Human health impacts merited just a few paragraphs and no mention was made of the effects of the carcinogens, mutagens, teratogens, respiratory irritants and the neurological, endocrine and haematological disruptors and toxins used in fracking. No potential social or ecological damage was considered.

A hydraulic fracturing site in South Montrose, Pennsylvania. Photograph: Spencer Platt/Getty Images

The PHE study has been dismissed by UK public health charity Medact, which is made up of around 900 health professionals. In a letter sent to Lancashire county council which will decide at the end of the month on Cuadrilla’s application to frack, Medact described the PHE study as “narrow, inadequate and incomplete” and said that it had arrived at an “erroneous, unsubstantiated and misleading” conclusion. “It formed its conclusions on the presumption of effective process management, operation and regulation,” said Medact.

Medact continued:

The claim of PHE that fracking is safe if properly practised and regulated cannot be substantiated on the basis of the available evidence which is inadequate and incomplete... Given the risks associated with fracking and the knowledge that the regulatory system is inadequate and under-resourced, the ‘precautionary principle’ points clearly to the need to reject the applications for exploratory fracking. Fracking is an inherently risky activity. Environmental pollution (air as well as ground and surface water) will occur at all stages of the shale gas extraction process. Outdoor air pollutants include volatile organic compounds, tropospheric ozone, and diesel particulate matter. Pollutants in ground and surface water include benzene, hydrocarbons, heavy metals and naturally occurring radioactive material. While some pollutants are known to have toxic and harmful properties, many have not been adequately studied while others have not been studied at all.

Fracking in Britain has barely started but is already making communities sick with worry. I called both the Department of Health and PHE to ask if they were commissioning any new studies or publishing any new reports in the light of the science emerging in the US, but spokesmen said they were not.

• This article was amended on 20 January to correct details about the Centre for Radiation, Chemical and Environmental Hazards’ report.